Compliance Verification Activity Report: CV2223-256 - Montreal Pipe Line Limited


Compliance verification activity type: Field Inspection

Activity #: CV2223-256
Start date: 2022-06-22
End date: 2022-06-22


Regulated company: Montreal Pipe Line Limited

Operating company: Montreal Pipe Line Limited

Province(s) / Territory(s):


Rationale and scope:

Field-based meeting with company and landowner to discuss landowner concerns. Discussion includes sampling locations and access issues.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Access concerns

Date & time of visit: 2022-06-22 10:00

Discipline: Environmental Protection




ATV/Motocross tracks were observed on the Right-of-way (RoW) from the top of the hill at Old Notch Road to the bottom of the hill at Davis Brook. The tracks, usually less than 2m in width, prevent revegetation which leads to erosion. It was agreed that by implementing measures to prevent access it would allow the vegetation to grow and significantly reduce the erosion issues. Water diversion berms installed in 2018 were observed every 10m to 15m. Most were very effective at diverting water and a few required some minor maintenance work. Various access mitigations were discussed with Montreal Pipeline and Nature Conservancy of Canada representatives. Due to the persistence of the access / trespass despite signage and gate type installations (gate and concrete blocks) at Old Notch Road, it was agreed that for a measure to be successful it would have to be implemented along the RoW at regular intervals. It was suggested that a mix of modified vegetation control (e.g., allowing shrubs to grow slightly more and limiting brushing) and falling mature trees onto the RoW at regular intervals would likely make it much harder for users to gain access to the RoW. It was agreed that measures would have to be implemented all along this section of the RoW from the bottom of the hill to the top. Once agreed upon, Montreal Pipeline plans to work with NCC to conduct this work, likely over the next two years.

Compliance tool used: No compliance tool used

Observation 2 - Initial Soil Sampling Plan

Date & time of visit: 2022-06-22 13:30

Discipline: Environmental Protection




The Inspection Officer accompanied by Montreal Pipeline representatives and a consultant hired by the landowner, visited the RoW and the area surrounding the end of Courser Road and Davis Brook. The landowner concerns were related to potential contamination found in the coating of the pipeline being eroded, transported down the hill and deposited in low lying areas or in a nearby pond. To explore the potential for contamination in the area, samples were taken in a number of locations including the below. 

  1. Up-slope, to consider the potential source area  - soil
  2. Mid-slope  - soil
  3. Base of the slope / Areas of obvious sediment deposition agreed upon by all present on site  - soil
  4. Along the high-water event flow path where sediment deposition would have occurred over the years  - soil
  5. Upgradient within Davis Brook  – water (background)
  6. At the base of the slope within Davis Brook - water
  7. Downgradient within the pond on the landowner's property  – water
  8. Background soil location 

The depth of the samples taken during this field visit varied from surface to approximately 25cm. At each sampling location a sample was taken as deep as the manual auger would allow, but additional excavation heavy equipment would be needed to sample deeper (e.g. 1m deep). Overall, 9 soil locations and 3 water locations were sampled during the field visit.

Next steps on the sampling plan will be determined based on the results and analysis.

Compliance tool used: No compliance tool used

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to:

- the condition of an authorization document that requires the implementation of that plan or procedure; or

- the relevant section of the regulations that requires implementation of that plan or procedure including those sections that require implementation of plans or procedures as a part of a Program